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The Story of Staples v. United States and the Innocent Machine Gun Owner: The Good, the Bad, and the Dangerous

Joseph Edward Kennedy

University of North Carolina

April 26, 2010

UNC Legal Studies Research Paper No. 1596222

Harold Staples claimed that he did not know that his rife was a machine gun. In Staples v. U.S., 511 U.S. 600 (1994), the Supreme Court held that the government had to prove such knowledge in order to convict him under the National Firearms Act. Staples’ story of a potentially innocent defendant prosecuted for things he did not know transformed how both federal and state courts interpreted criminal statutes with ambiguous mental state requirements. Staples established the proposition that courts should read knowledge requirements into statutes that criminalized conduct that would be otherwise innocent, particularly when serious punishment was at stake. At the heart of the Staples case, however, was a series of choices by the lawyers involved that shaped the case in ways not evident from the four corners of the Supreme Court’s opinions in the case. Ultimately the Staples decision was about character, and a fuller understanding of the Staples case helps us better understand the role that character plays in both the public welfare offense doctrine and in mens rea more generally: The lesson of the Staples case is that courts are most likely to raise mens rea requirements when statues clearly designed for the very bad may end up being successfully used against the possibly good.

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Date posted: April 26, 2010  

Suggested Citation

Kennedy, Joseph Edward, The Story of Staples v. United States and the Innocent Machine Gun Owner: The Good, the Bad, and the Dangerous (April 26, 2010). UNC Legal Studies Research Paper No. 1596222. Available at SSRN: https://ssrn.com/abstract=1596222 or http://dx.doi.org/10.2139/ssrn.1596222

Contact Information

Joseph Edward Kennedy (Contact Author)
University of North Carolina ( email )
Van Hecke-Wettach Hall, 160 Ridge Road
CB #3380
Chapel Hill, NC 27599-3380
United States

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